Republic of the Philippines)
Davao City
)
x----------------------------x
JIONT COUNTER AFFIDAVIT
We, TEBAN ESCUDERO, GOLIATH ESCUDERO, ANDRES
ESCUDERO, MANUEL MABINI and GABRIELA MABINI, of legal
age, Filipino, and a residents of Brgy. Caburan, Jose Abad Santos,
Davao Occidental, after having been sworn to in accordance with law,
do hereby depose and state that:
1.
We
are
the
same
TEBAN
ESCUDERO,
GOLIATH
ESCUDERO, ANDRES ESCUDERO, MANUEL MABINI and
GABRIELA MABINI, who is now defendant in Criminal Cases
Numbered 648-B-205 now pending in Branch 2, of the
Regional Trial Court 12th Judicial Region, Province of
Davao Occidental brought by Pedro Santos.;
2. We vehemently and categorically deny the allegations in the
Affidavit-Complaint filed by Pedro Santos the same being untrue,
unfair and malicious;
3. We admit the allegations paragraph 3-10 of the said Affidavit
Complaint that we are regular employees of the said company.
4. We deny that allegation in paragraph 11 of the truth of the
matter is that the allegation of MARIO MASANGKAY is
malicious motivated by hate, anger and done through hidden
grudges with due to the fact that he was a former employee of
the said rice mill and was caught in the act of stealing spare
parts from our motor vehicles by security guards on duty namely
MANUEL MABINI AND GABRIELA MABINI which resulted to
his termination.
5. We have no knowledge of the allegations in paragraph 12 of
the complainants affidavit complaint on the said day when a
typhoon hit the municipality of Jose Abad Santos. We were in our
homes tending to our respective families.
1
Counter Affidavit
IN WITNESS WHEREOF, we have
hereunto affixed my
signature this ______ day of ___________ 2016, Davao City,
Philippines.
TEBAN ESCUDERO
AFFIANT
ANDRES ESCUDERO
AFFIANT
GOLIATH ESCUDERO
AFFIANT
MANUEL MABINI
AFFIANT
GABRIELA MABINI
AFFIANT
SUBSCRIBED AND SWORN to before me this _______ day of
_____________ 2016 at Davao City, Philippines. I hereby certify that
I have examined the affiant and that I am satisfied that he fully
understands the contents of his affidavit.
Doc. No. ____;
Page No. ____;
Book No. ____;
Series of 2016.
2
Counter Affidavit